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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Region 4 

Atlanta, Georgia 

Preliminary Determination & Statement of Basis

Outer Continental Shelf Air Permit OCS-EPA-R4008-M2

for

BHP Billiton Petroleum, Inc.

Sake Prospect Drilling Project

May 23, 2013
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1.0 Introduction

On May 30, 2012, the U.S. Environmental Protection Agency (the EPA) issued an Outer Continental 

Shelf (OCS) permit (Permit No. OCS-EPA-R4008) to BHP Billiton Petroleum, Inc. (BHPB) in 

accordance with the provisions of section 328 of the Clean Air Act (CAA), 42 U.S.C. § 7627, and the 

implementing Outer Continental Shelf (OCS) Air Regulations at title 40 Code of Federal Regulations

(CFR) part 55.

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This permit to construct and operate emissions units at exploratory drilling operations in 

the DeSoto Canyon area of the Eastern Gulf of Mexico (known as the Sake Prospect Drilling Project or 

Sake Project) became effective on June 30, 2012. Subsequently, a minor permit revision was made to 

this permit (Permit No. OCS-EPA-R4008-M1) on March 13, 2013, to include activities that were 

previously omitted from the original application (e.g., painting, welding, flaring, and seismic 

operations).

On May 3, 2013, BHPB submitted to the EPA an application to update the potential to emit estimates for 

their operation and to revise the Best Available Control Technology (BACT) emissions limits for the

eight main engines of the Development Driller 1 (DD1), originally specified in Permit No. OCS-EPAR4008, for particulate matter (PM), particulate matter with an aerodynamic diameter equal to or less 

than 10 microns (PM10) and particulate matter with an aerodynamic diameter equal to or less than 2.5

microns (PM2.5), volatile organic compounds (VOC), and greenhouse gases (GHGs), measured as CO2e. 

BHPB requested these revisions because the original permit limits for these pollutants were established 

using AP-42 emissions factors, and source test data is now available which more accurately reflects the

emissions from the engines on the drilling rig operating under the terms and conditions of the permit.

Following careful consideration and analyses of the data provided by BHPB, the EPA is proposing to 

revise the BACT limits for PM, PM10, PM2.5, VOC, and CO2e for units EU-001 through EU-008 on the 

DD1 as specified in Conditions 6.6.1.1.3 through 6.6.1.1.5 of Permit No. OCS-EPA-R4008-M2, as 

summarized below. In general, the revised emission limits for PM, VOC, and GHGs are higher than 

those in the original permit. The EPA is also incorporating high and low load limits that are more 

reflective of the variable load operations of these engines when operating under the terms of the permit. 

This revision does not constitute a modification of the facility nor a change in the proposed drilling 

operations. While BHPB has made preparations to drill, including source testing, BHPB has not yet 

begun drilling operations on the lease blocks covered by the permit. Rather, this action is a proposed 

revision to a limited number of emissions limits, relating to specific engines on the DD1, to reflect data 

that is more representative of operations of the engines when the facility is operating subject to the terms 

and conditions of the permit. All other aspects of the permit remain the same. 

This document serves as a fact sheet, preliminary determination, and statement of basis for the draft 

permit revisions. This document addresses the changes made to the original preliminary 

determination/statement of basis as a result of this permit revision. A description of the project, a 

summary of the applicable requirements, the legal and factual basis for the draft permit conditions, and 

the EPA’s analysis of key aspects of the application and permit such as the BACT analysis and air 

quality impact analysis can be found in the original statement of basis for this permit, which is available 

in the administrative record for this project, as discussed in Section 9 of this document.2The EPA has 

 

1

See CAA § 328. EPA Region 4 is the agency responsible for implementing and enforcing CAA requirements for OCS sources in the Gulf 

of Mexico east of longitude 87°30‘ (87.5° W). The Department of Interior has jurisdiction for Clean Air Act implementation west of 

87°30’.

2 The procedures govering the issuance of both OCS and PSD permits are set forth at 40 CFR part 124, subparts A and C. See 40 CFR §§ 

55.6(a)(3) and 124.1. While these regulations do not address permit revisions, given the nature of the revisions, the EPA has followed the 
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retained the section numbers in this document that correspond to the original Statement of Basis to 

facilitate review.

2.0 Applicant Information

2.1 Applicant Name and Address

BHP Billiton Petroleum, Inc.

1360 Post Oak Blvd., Suite 150

Houston, Texas 77056

2.2 Facility Location

BHPB plans to conduct exploratory drilling at multiple sites in the OCS waters of the Gulf of Mexico, 

DeSoto Canyon area, within lease blocks 499, 543-545, 586-592, 631-640, 676-685, 721-729, 768-773, 

and 815-817, Figure 2-2. These 49 contiguous lease blocks are located approximately within latitudes 

28.15° to 28.50° N and longitudes 86.68° to 87.27° W, east of longitude 87.5° W. The center of the lease 

block area is located at latitude 28.31° N and longitude 86.96° W, approximately 120 miles southeast of 

the nearest Louisiana shoreline, 139 miles south southeast of the nearest Mississippi shoreline, and 125 

miles south of the nearest Alabama and Florida shorelines.

3.0 Project Description

For the Sake Project, BHPB plans to conduct exploratory oil and natural gas drilling using a mobile 

offshore drilling unit (MODU) for a period of up to two years. For operational flexibility, BHPB will 

use either the Transocean ultra-deepwater MODU C.R. Luigs (Operating Scenario 1) or the Transocean 

semi-submersible MODU DD1 (Operating Scenario 2) and an associated support fleet in multiple 

locations within its DeSoto Canyon lease blocks as discussed above. The project will last a maximum of 

two years and, based on applicable permitting regulations, qualifies as a “temporary source” for 

Prevention of Significant Deterioration (PSD) permitting purposes.

Air pollutant emissions generated from the Sake Project include carbon monoxide (CO), nitrogen 

dioxide (NO2), PM (which includes PM10 and PM2.5), and sulfur dioxide (SO2) (known as criteria 

pollutants), as well as other regulated air pollutants, including oxides of nitrogen (NOX), VOC, and 

GHGs. VOC and NOX are the measured precursors for the criteria pollutant ozone, and NOX and SO2

are measured precursors for the criteria pollutant PM2.5.

These emissions are primarily released from the combustion of diesel fuel in the MODU’s main diesel 

engines used for electric power generation for dynamic position station-keeping and drilling operations. 

Diesel engines are also used to run cranes, a black start compressor, cementing operations, wireline 

units, and support vessels operating within 25 miles of the MODU. The emergency generator, life boats, 

and the fast rescue craft are also powered by diesel engines and are routinely operated for testing and 

 

procedures of 40 CFR part 124 in issuing these draft permit revisions. The EPA is also following the procedures of 40 CFR part 71 

governing the revision of federal operating permits. This Preliminary Determination describes the revisions to the permit conditions and the 

reasons for them as provided in 40 CFR § 124.7, and also serves as a Fact Sheet as provided in 40 CFR § 124.8 and a statement of basis 

required by 40 CFR § 71.11(b).
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maintenance, releasing additional emissions. In addition, there are additional PM/PM10/ PM2.5 emissions 

from the mud and cement dust collectors. Additional VOC and GHG emissions are released from a mud 

degassing unit and the storage tanks used to store diesel fuel, hydraulic oil, base oil, and jet A helifuel.

Based on emissions estimates, the Sake Project has the potential to emit the regulated New Source 

Review (NSR) pollutants CO, NOX, PM/PM10/ PM2.5, VOC, and GHGs above their PSD significant 

emission rates. Hence, the original permit incorporated the results of the PSD BACT analysis, air quality 

analysis, monitoring, reporting, and recordkeeping requirements for the applicable emission sources 

releasing these pollutants.

Included in their application to revise the BACT emission limits for the specified DD1 engines, BHPB 

performed a revised BACT analysis, a revised air quality analysis, and updated its Potential to Emit 

(PTE) for regulated NSR pollutants, as discussed below.

4.0 Regulatory Applicability

4.3 Prevention of Significant Deterioration 

The project potential to emit values shown in Table 4-1 have been updated following the receipt of the 

stack test data for PM, PM10, PM2.5, VOC, and CO2e emissions for the DD1’s main engines and the 

revision of the respective BACT limits for these pollutants, as detailed in Section 6. With respect to the 

PM, PM10, and PM2.5 emissions, BHPB proposed in this permit amendment to use filterable PM results 

and particle size distribution information from AP-42 to calculate PM10 and PM2.5 emission rates. 

However, based on the preliminary stack test data, the condensable particulate appears to be a 

substantially higher percentage (upwards of 82 percent) of the filterable particulate than what is 

predicted by AP-42 (approximately 12 percent) for large diesel engines. In other words, it is difficult to 

differentiate between the condensable and filterable particulate. Given that the AP-42 factors have an 

“E” rating (i.e. are based upon testing conducted on a single engine), and absent more reliable data, the 

EPA believes a more appropriate methodology for calculating potential particulate emissions is to 

assume that all filterable particulate is PM10/PM2.5 and, thus, total PM is PM10/PM2.5 for the main 

engines of the DD1. The resulting PM10/PM2.5 PTE for the project, as calculated by the EPA is, 

therefore, higher than that estimated by BHPB in the application (see Tables 4-1 and 5-2 below). It 

should be noted that since these limits are based on the worst-case emission rates, which the variable 

load drilling rig does not operate at continuously, the EPA believes these estimates are conservative.
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Table 4-1: Potential to Emit for Regulated NSR Pollutants

Pollutant

C.R. Luigs

PTE

(TPY)

DD1

PTE

(TPY)

Significant 

Emission Rate 

(TPY)

PSD

Review 

Required?

PM 66.02 77.28 25 Yes

PM10 41.15 72.44 15 Yes

PM2.5 40.16 72.26 10 Yes

NOX

a

1,699.60 1,309.61 40 Yes

SO2

b

0.91 0.88 40 No

H2SO4 0.03 0.03 7 No

CO 373.69 310.64 100 Yes

VOCc81.61 110.48 40 Yes

GHGs (CO2e) 101,574.72 111,088.86 75,000 (subject to

regulation threshold) Yes

Lead 0.02 0.02 0.60 No

 a

NOX is a measured pollutant for the criteria pollutants ozone and NO2 and a precursor for PM2.5.

b

SO2 is a precursor for the criteria pollutant PM2.5. 

c

VOC is a measured pollutant for the criteria pollutant ozone.

4.4 Title V

The requirements of the title V operating permit program, as set forth at 40 CFR part 71, apply to major 

OCS sources located beyond 25 miles of states’ seaward boundaries. Because the PTE for this project is 

greater than 100 TPY for NOX and CO, it is considered a major source under title V and part 71. The 

title V permit requirements were included in the OCS permit issued for this source on May 30, 2012. 

The proposed permit changes constitute a significant modification to the title V permit because they do 

not meet the criteria set out for a minor modification under 40 CFR 71.7(e)(1). More specifically, the 

revisions require a case-by-case determination of emissions limits. As discussed in Section 1, above, 

while the permit revisions constitute a “modification” pursuant to part 71, they do not constitute a 

modification to the emissions units or planned operation of the facility (i.e., this is not a physical change 

or a change in the method of operation, as defined under PSD). The required Part 71 forms are included 

in Section 7 of BHPB’s permit modification application received by the EPA on May 3, 2013. The 

permit continues to include all the permit terms necessary to meet the requirements of the applicable title 

V operating permits program. For example, the permit includes requirements for submittal of annual 

compliance certifications and annual fee payments, based on actual emissions, as well as monitoring, 

recordkeeping, and reporting requirements.

4.6 National Emission Standards for Hazardous Air Pollutants (NESHAP)

Since the original permit was issued, proposed amendments to the reciprocating internal combustion 

engine (RICE) maximum achievable control technology (MACT) rule (40 CFR part 63, subpart ZZZZ) 

were made final (on January 30, 2013). Basically, units that are existing stationary, non-emergency, 

compression-ignition RICE with a site rating of more than 300 horsepower, located on an offshore 

vessel that is an area source of HAP, and is a non-road vehicle that is an OCS source (as defined in 

40 CFR § 55.2), are no longer subject to the numerical CO emission limits of Table 2d of the MACT. 

However, the following management practices must be met:

 Change oil every 1,000 hours of operation or annually, whichever comes first. Or, utilize an oil 

analysis program as prescribed in 40 CFR § 63.6625(i) in order to extend the specified oil 

change requirement;
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 Inspect and clean air filters every 750 hours of operation or annually, whichever comes first, and 

replace as needed;

 Inspect fuel filters and belts, if installed, every 750 hours of operation or annually, whichever 

comes first, and replace as needed; and

 Inspect all flexible hoses every 1,000 hours of operation or annually, whichever comes first, and 

replace as needed.

Additionally, pursuant to 40 CFR § 63.6655, records of the above management practices need to be 

maintained in readily-accessible, hard, or electronic form for at least five years following the date of 

each maintenance activity. No change is necessary to the permit to reflect this change. However, the 

EPA is including this information to update the Statement of Basis to reflect the current applicability of 

the RICE MACT.

5.0 Project Emissions

The table below provides the revised PTE of the project using the DD1 Operating Scenario, based on the 

recent source testing results for the eight main diesel engines. No changes are proposed for the other 

emissions units.

Table 5-2: Potential to Emit Emissions – DD1 Operating Scenario 2

Emission 

Source

PM 

(TPY)

PM10

(TPY)

PM2.5

(TPY)

NOX

(TPY)

SO2 

(TPY)

H2SO4

(TPY)

CO 

(TPY)

Total 

VOC

(TPY)

Lead 

(TPY)

GHGs 

(CO2e) 

(TPY)

Main Diesel Engines 

(8) 61.92 61.92 61.92 1,007.02 0.70 0.02 215.09 66.99 1.34E-02 90,056.47

Emergency 

Generator Engine (1) 0.05 0.03 0.03 1.60 0.001 2.21E-05 0.37 0.04 1.36E-05 77.84

Lifeboat Engines (4) 1.21E-02 1.21E-02 1.21E-02 1.71E-01 5.82E-05 1.82E-06 3.67E-02 1.38E-02 1.12E-06 6.35

Fast Rescue Craft 

Engine (1) 3.91E-03 3.91E-03 3.91E-03 5.50E-02 1.88E-05 5.87E-07 0.01 4.46E-03 3.06E-07 2.05

Cementing Unit 

Engines (4) 0.41 0.25 0.25 9.50 0.01 2.03E-04 3.73 0.57 1.25E-04 715.48

Mud & Cement Dust 

Collectors (2)

1.08 1.08 1.08 - - - - - - -

Mud Degassing 

Operation (1) - - - - - - - 19.39 - 982.67

Wireline Unit 

Engines (4)

0.60 0.60 0.60 8.92 0.005 1.54E-04 2.90 1.17 9.44E-05 536.63

MODU Storage 

Tanks (26) - - - - - - - 0.44 - -

Work Boats (2) 9.70 5.58 5.42 246.82 0.15 4.57E-03 76.01 8.90 2.80E-03 16,080.92

Work Boats Storage 

Tanks (52)

- - - - - - - 9.47E-02 - -

Fast Crew Boats (1) 1.41 0.87 0.85 31.94 0.02 6.19E-04 10.38 1.33 3.80E-04 2,180.77

Crew Boat Storage 

Tanks (2) - - - - - - - 6.02E-03 - -

Flaring Operations - - - 0.03 - - 0.18 0.07 - 64.72

Welding Operations 0.02 0.02 0.02 - - - - - - -

Painting Operations 1.96 1.96 1.96 - - - - 4.79 - -

Seismic Operations

(3 Engines) 0.11 0.11 0.11 3.54 3.77E-03 1.18E-04 1.94 6.67 6.82E-05 384.97

Emission Unit 

Totals: 77.28 72.44 72.26 1,309.61 0.88 0.03 310.64 110.48 0.02 111,088.86
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6.0 Best Available Control Technology (BACT)

The top-down BACT analysis conducted by the applicant in conjunction with this latest revision was 

essentially unchanged from the original application, and did not result in any significant changes to the 

respective control technology determinations for the main engines of the DD1. This is as expected, since 

the applicant has not proposed to change any emissions units nor the method of operation. BHPB 

requested revisions to certain BACT limits because the original permit limits for these pollutants were 

established using AP-42 emissions factors, and source test data is now available which more accurately 

reflects the emissions from the engines on the drilling rig operating under the terms and conditions of 

the permit. Following careful consideration and analyses of the data provided by BHPB, the EPA is 

proposing to revise the BACT limits for PM, PM10, PM2.5, VOC, and CO2e for units EU-001 through 

EU-008 on the DD1 as discussed below.

Initial compliance stack testing, which commenced on March 31, 2013, in accordance with Condition 

6.9.1.3, yielded data that was generally higher than the respective BACT limits for PM/PM10/PM2.5, 

VOC, and CO2e, especially at low loads. The original emission estimates and BACT limits were based 

on AP-42 emission factors due to the lack of actual emissions data for the aforementioned pollutants on 

this drilling rig or like drilling rigs. The AP-42 factors that were relied upon by the applicant (Section 

3.4, Large Stationary Diesel and All Stationary Duel-Fuel Engines) are from a very limited sampling 

(i.e., the testing of one engine only) and, thus, do not carry a very favorable rating in terms of 

accuracy/reliability. Furthermore, the AP-42 factors are more representative of land-based rather than 

marine-based applications and specifically do not account for the frequent variable load scenarios and 

operating characteristics associated with drilling operations. Nonetheless, these factors were the best 

available at the time the permit was written. Preliminary results from the recent stack tests on the DD1

drilling rig showed the emissions of NOX and CO from the main engines will be in compliance with the 

BACT limits established in the original permit. These limits were established using source test data from 

this source and other like engines.

BHPB proposed revised BACT emission limits for PM, PM10, PM2.5, VOC, and CO2e for units EU-001 

through EU-008 on the DD1 based on compliance stack test results. The stack test was performed for 

three runs each at high, medium and low loads. A single BACT limit was proposed by BHPB for each 

pollutant that generally correlated to highest 3-run average test result from a single engine, irrespective 

of the operating load. Upon analysis of the data, however, EPA determined that separate emission limits 

for low load and high load operations are more appropriate for the particulate matter emission limits as 

well as VOC. While emission rates at high and medium load are similar for these pollutants, there is a 

significant difference in the emission rates when tested at low loads. This is expected due to the 

combustion characteristics of the diesel engines. In addition, in establishing the BACT limits, EPA 

considered correlation of the data across the test runs, as significant deviations may be an indicator of 

poor test results or operations outside of optimum performance. 

The revised BACT limits for PM/PM10/PM2.5 and VOC were established for low and high engine load 

scenarios (i.e., less than 55 percent and greater than or equal to 55 percent loads) (see Tables 6-3 and 6-

4). The EPA has established high and low load emission rates to ensure that when the engines are 

operating at high loads, they will continue to be required to be maintained, employ the best combustion 

practices, meet the emission rates achievable through the use of the prescribed BACT control 

technologies.

One update to the original control technology analysis has now been incorporated into the permit. Highpressure fuel injection (HPFI)/high-efficiency fuel injection (HEFI) has been now deemed to be BACT 
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with respect to CO2e. HPFI/HEFI was previously deemed to be BACT for other pollutants and the 

technology is already present on the main engines of the DD1, as necessary to comply with the permit 

terms and conditions.

6.1 BACT Analysis for Internal Combustion Engines

The EPA refers interested parties March 30, 2012 statement of basis, included in the permit record, for 

the EPA’s comprehensive BACT analysis. The revised BACT emissions limits that were incorporated in 

the permit are given in the tables below. It should be noted that these BACT limits may again change as 

more representative emissions data is acquired by the source and similar drilling rigs during the permit 

term. 

6.1.2 CO and VOC BACT Analyses for Internal Combustion Engines

Table 6-3: VOC BACT Conclusions

Emissions 

Unit ID BACT Control Options VOC BACT Limits*

Vessel: DD1

EU-001 

through

-008

PCV, HPFI w/ aftercooler, and 

good combustion practices with use 

of DEWT measurement system

1.02 x 10-3lb/hp-hr (0.62 g/kW-hr) for engine 

loads < 55%

8.22 x 10-4lb/hp-hr (0.50 g/kW-hr) for engine 

loads ≥ 55%

*Short-term limits are based on a rolling 24-hour average and long-term limits (including hours of operation) are based on a 

rolling 12-month period.

6.1.3 PM/PM10/PM2.5 BACT Analysis for Internal Combustion Engines

Table 6-4: PM/PM10/PM2.5 BACT Conclusions

Emissions 

Unit ID BACT Control Options PM/PM10/PM2.5 BACT Limits*

Vessel: DD1

EU-001 

through

-008

Turbocharger and aftercooler, 

PCV, HPFI w/ aftercooler, good 

combustion practices with the 

use of DEWT measurement 

system, and ultra low sulfur fuel

9.37 x 10-4lb/hp-hr (0.57 g/kW-hr) for engine loads 

< 55%

7.07 x 10-4lb/hp-hr (0.43 g/kW-hr) for engine loads 

≥ 55%

*Short-term limits are based on a rolling 24-hour average and long-term limits (including hours of operation) are based on a 

rolling 12-month period.
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6.1.4 GHG BACT Analysis for Internal Combustion Engines

Table 6-5: GHG BACT Conclusions

Emissions 

Unit ID BACT Control Options BACT Limits* (as CO2e)

Vessel: DD1

EU-001 

through

-008

HPFI/HEFI, good 

combustion practices with 

use of DEWT 

measurement system

1.36 lb/hp-hr (829 g/kW-hr) 90,056.47 tons per year

6,570 hours of operation

*Short-term limits are based on a rolling 24-hour average and long-term limits (including hours of operation) are based on a 

rolling 12-month period. All GHG emission limits are in the form of CO2e.

7.0 Air Quality Impact Analyses Summary

7.2.6 Modeling Results

Because the permit continues to limit BHPB’s exploratory drilling project in the Desoto Canyon lease 

blocks to no more than two years, the project qualifies as a temporary emissions source for purposes of 

PSD permitting. Because the revised emissions for particulate matter are higher than those originally 

proposed for the project, the applicants submitted a revised PM/PM10/PM2.5 modeling analysis.

BHPB used the same modeling approach and stack parameters as used in the original application. A 

Class I area modeling analysis was performed with the revised worst case project emission rates for the 

Breton National Wildlife Refuge (NWR), the St. Marks NWR and the Bradwell Bay Wilderness Area. 

The worst-case mass emission rates (38.62 lb/hr for both PM10 and PM2.5) conservatively include an 

emission rate for DD1’s main engines which is higher (0.63 g/kW-hr) than the new PM10/PM2.5 BACT 

limits (0.57 and 0.43 g/kW-hr). Based on the EPA’s review of this modeling and input received from the 

Federal Land Manager regarding their review of the Air Quality Related Values and visibility impact 

modeling assessment, the project applicant has continued to demonstrate that the proposed project does 

not impact any PSD Class I area. This analysis is available in the administrative record, as discussed in 

Section 9 below.

9.0 Public Participation

9.1 Opportunity for Public Comment

The EPA is using the procedures for decision making, set forth at 40 CFR part 124 to process this permit 

revision. While neither the OCS nor PSD regulations address the administrative procedures for permit 

revisions, given that the revisions change the BACT emission limits previously offered for public 

comment, the EPA is following the procedures of 40 CFR part 124 and 40 CFR part 71 in processing 

this revision. As required by these provisions, the EPA is seeking public comment on the revisions 

incorporated into BHPB OCS air permit OCS-EPA-R4008-M2.
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Any interested person may submit written comments on the draft revisions to the permit during the 

public comment period. If you believe that the revisions to the permit are inappropriate, you must raise 

all reasonably ascertainable issues and submit all reasonably available arguments supporting your 

position by the end of the comment period. Any documents supporting your comments must be included 

in full and may not be incorporated by reference unless they are already part of the record for this permit 

or consist of state or federal statutes or regulations, EPA documents of general applicability, or other 

generally available referenced materials. 

Comments should focus on the revisions to the air quality permit. If you have general comments

regarding non-air quality impacts, leasing, drilling safety, discharge, or other similar issues not subject 

to this public comment period, you should submit them during the leasing and permitting proceedings of 

the Bureau of Ocean Energy Management, which is the lead approval agency for offshore drilling.

All timely comments on the draft revisions will be considered in making the final decision and will be 

included in the record, and responded to by the EPA. The EPA may group similar comments together in 

our response and will not respond to individual commenters directly. 

All comments on the draft permit must be received by email, submitted electronically at

www.regulations.gov, or postmarked by June 24, 2013. Requests for a Public Hearing (see below) must 

be received by email or mail by June 10, 2013. An extension of the 30-day comment period may be 

granted if the request for an extension adequately demonstrates why additional time is required to 

prepare comments. Comments can be sent by email, delivered in writing to the address below or 

submitted electronically via www.regulations.gov, which can be accessed through the EPA Region 4 

website listed below. All comments will be included in the public docket without change and will be 

made available to the public, including any personal information provided, unless the comment includes 

Confidential Business Information or other information in which disclosure is restricted by statute. 

Information that you consider Confidential Business Information or otherwise protected should be 

clearly identified as such and should not be submitted through e-mail. If you send e-mail directly to the 

EPA, your email address will be captured automatically and included as part of the public comment. 

Please note that an e-mail or postal address must be provided with your comments if you wish to receive 

direct notification of the EPA’s final decision regarding the permit and the EPA’s response to comments 

submitted during the public comment period. For questions on the draft permit, please contact: Mr. Art 

Hofmeister at 404-562-9115 or hofmeister.art@epa.gov. Submit comments on the draft permit and 

requests for a public hearing to:

EPA Region 4, APTMD

Air Permits Section

61 Forsyth Street, SW

Atlanta, GA 30303

ATTN: Art Hofmeister

Fax: (404) 562-9019

Email: hofmeister.art@epa.gov

9.2 Public Hearing 

The EPA will hold a public hearing if the Agency determines that there is a significant degree of public 

interest in the draft permit. Requests for a public hearing must be received by the EPA by email or mail 

by June 10, 2013, at the address given above, and state the nature of the issues proposed to be raised in 
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the hearing. You may submit oral or written comments on the draft permit at the public hearing. You do 

not need to attend the public hearing to submit written comments. If EPA determines that there is a 

significant degree of public interest, the EPA will hold a public hearing the week of June 24, 2013, at the 

location given on the EPA’s website (see below). If no timely request for a public hearing is received, or 

the EPA determines that there is not a significant degree of public interest, an announcement will be 

posted on the EPA’s website by June 12, 2013, at: 

http://www.epa.gov/region4/air/permits/ocspermits/ocspermits.html,

or, you may call the EPA at the contact number above to determine if the public hearing will be held.

9.3 Administrative Record

The administrative record contains the application, supplemental information and data submitted by 

BHPB, and correspondence, including e-mails between BHPB and its consultants and the EPA 

clarifying various aspects of BHPB’s application. The EPA’s draft permit revisions and preliminary 

determination/statement of basis, comments received from the public or other government agencies and 

the applicant during the public comment period, become part of the administrative record for the permit. 

The draft permit revision and the administrative record are available for public review on the EPA’s 

website at:

http://www.epa.gov/region4/air/permits/ocspermits/ocspermits.html

and at the EPA Region 4 office at the addresses listed below. Please call in advance for available 

viewing times.

EPA Region 4 Office

61 Forsyth Street, SW

Atlanta, GA 30303

Phone: (404) 562-9643

To request a copy of the draft permit, preliminary determination or notice of the final permit action, 

please contact: Ms. Rosa Yarbrough, Permit Support Specialist at (404) 562-9643 or 

yarbrough.rosa@epa.gov.

9.4 Final Determination

A final decision to issue the final permit revision, or to deny the application for the permit revisions, 

shall be made after all timely comments have been considered. Notice of the final decision shall be sent 

to each person who has submitted written comments or requested notice of the final permit decision, 

provided the EPA has adequate contact information.